recruit participants from certain groups or populations, such
as undocumented immigrants or people who do not trust the
ability of organizations to protect sensitive data. While this
may not cause problems in some studies, in other studies it
may prevent researchers from gathering socially important
How do institutions generally react to this tension between
tax law, on the one hand, and respect for research participants
and the quality of science, on the other? The answer is highly
variable. My staff and I pulled policies for the payment of
research participants from the websites of 30 research-intensive
institutions and found that four of them required SSNs to be
collected for all payments. At the other extreme, 13 institutions
required SSNs to be collected only for payments of $600 or
more. According to my discussions with tax advisors, variation
is driven primarily by how institutions choose to balance
the management of legal risk created by IRS rules with the
protection of and respect for participants in research.
The fact that federal taxpayers subsidize major funders of
research such as the NIH and National Science Foundation
suggests that we as a society view research as contributing to the
public good by improving health, education and technologies.
If this is true, then it might make sense for the IRS to exempt
payments for research participation from taxable events —
at least when payment for any single study is under the IRS
threshold of $600 a year. In the meantime, institutions will need
to continue doing their best to balance compliance with federal
tax law with concern for the protection and preferences of
research participants. n
James DuBois, DSc, PhD, is professor of medicine and director of
the Center for Clinical Research Ethics at Washington University School of Medicine. He is a member of the APA Committee on
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